As a lobbyist your job is going to be full of variety.
Given that variety, it helps to have the right ‘map’ to guide you through your journey.
EU law making is not fast. It is full of opportunities to intervene and make your case.
During your journey, you’ll need a detailed paper or electronic road map.
Sometimes, you are going to need country and city specific maps.
You’ll need to make sure that the map that you are using is up to date.
Today, you can use GPS. Sometimes it is up to date, but it may not tell you when a motorway is out of action.
Maps are not usually transferable
Today, I spend a lot of time on chemical legislation and policy. . I deal a lot with substances being added to the CLP’s Annex and REACH.
With time, you get to learn the process, steps, and issues you can and can’t raise. You get to understand the map and best routes to take and as importantly avoid.
Yet, I have worked in other areas, like fisheries, where the map is totally different.
Lobbyists working in fiance use a very different map.
For me, there would be no point in blindly re-using the map I used in fisheries in chemicals. I’d at best get lost very quickly, and more likely far worse.
Case Study – CLP 10th ATP
I like case studies. It is the inner lawyer lurking in me. You can learn a lot looking at the precedents. No all cases go the same, and exceptions happen. Yet, the case below, provides a good example of the usual process and timescale, for updating the ATP.
The case here is the 10th ATP. I choose this for no better reason than it was tabled and adopted under this Commission.
To date, no CLP ATP updates have gone through the ‘Better Regulation’ 4 week public consultation. There is no evidence of the 10th ATP going through the Better Regulation public consultation. My own view is that they should.
Unfortunately, in the case study below, the dates for inter-service consultation for the adoption of the proposal are not listed. The Commission keep this part of the process, arguably the most important, away from public view.
Key Dates
1. CARACAL – list of substances for possible inclusion for which the European Chemicals Agency (ECHA) has adopted opinion in 2015 (or earlier) was circulated for feedback and comments to by 8 April 2016 24 February 2016
2. CARACAL informed of 10th ATP 23 March 2016
3. REACH Regulatory Committee informal discussion on 10th ATP 7 July 2016
4. Commission submits Draft Measure to WTO 15 September 2016
5. WTO Consultation on 10th ATP closed 21 October 2016
6. Member State experts (REACH Regulatory Committee) approve update to ATP 26 October 2016
26 Member States in favour, 2 against
7. Commission ask delegations to express objections possible opposition to draft measure 11 November 2016
8. Deadline for delegations to express possible opposition to draft measure 12 December 2016
9. No objection Permanent Representatives Committee (COREPER) 13 January 2017
10. Council confirm (link) no objection 23 January 2017
11. Deadline for EP & Council to object 10 February 2017
EP & Council no objection
12. Adopted 5 May 2017 – Commission Regulation (EU) 2017/776 5 May 2017
13. Entry into Force 25 May 2017
14. Apply from 1 December 2018